ML20133D387
| ML20133D387 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/03/1985 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8507220187 | |
| Download: ML20133D387 (3) | |
Text
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General offices. 1945 West Pernall Road, Jackson, MI 49201. (517) 788-1636 July 3, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO IE INSPECTION REPORT 85-009 One item of noncompliance was identified in Inspection Report 50-255/85-009 dated June 3, 1985.
In addition, the Inspection Report cover letter requested that a description be provided of the measures to be taken to cause safety evaluations to occur prior to modifying the plant or systems as described in the FSAR. The following are our responses to the item of noncompliance and the requested description.
Noncompliance 50-255/85-009-01 10CFR50.59 specifies that changes may be made in the facility
"...as described in the safety analysis report...without prior Commission approval, unless the proposed change... involves...an unreviewed safety question".
Furthermore,
"...the licensee shall maintain records of changes in the facility...made pursuant to this section, to the extent that such changes constitute changes in the facility as described in the safety analysis report...
These records shall include a written safety evaluation which provides the bases for the determination that the change...does not involve an unreviewed safety question..."
Contrary to the above, the licensee failed to perform a 10CFR50.59 review evaluating the safety significance of leaving the East Safeguards Room air cooler isolated from March 6, 1985 until repairs to the cooler could be made.
Isolation of the cooler (described in the Final Safety Analysis Report (FSAR) as operating automatically) constituted an unreviewed change from the FSAR in that cooler operation would have required operator action (ie, it would not have operated automatically) to be placed in service.
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James G Keppler, Administrator 2
Palisades Plant Response to IEIR 85-009 July 3, 1985
Response
Discussion:
The cover letter to Inspection Report 50-255/85-009 requested that a description be provided of the measures to be implemented to cause safety evaluations to be made prior to modifying the plant or systems as described in the FSAR. The circumstances of this occurrence were reviewed to determine the appropriate response to this request.
Plant procedures require safety evaluations to be performed for items such as procedures, modifications, and setpoint changes. These are the routine items that will normally cause changes in the plant from the FSAR description.
In addition, Plant Review Committee (PRC) reviews and management review of corrective action items through the Corrective Action Review Board (CARB) also assure. safety evaluations are performed.
PRC reviews include safety-related matters such as procedures and modifications.
CARB reviews include safety-related equipment and procedural problems that occur during daily operation. Through these activities, assurance is provided that an adequate Safety Evaluation will occur for routine modifications and for abnormal plant conditions.
The controls imposed by these administrative requirements are adequate to ensure Safety Evaluations occur. The violation identified in this inspection resulted from a judgement error by personnel acting within these controls.
Training sessions are to be provided to CARB and PRC members and Operations personnel to review the appropriate 10CFR50.59 requirements. Increased awareness of Safety Evaluations and the attendant restrictions imposed by 10CFR50.59 will prevent recurrence of similar cognitive errors.
Corrective Actions Taken And Results Achieved The East Safeguards Room Air Cooler was restored to a normal operating configuration. The occurrence was reviewed by the Plant Review Committee (PRC). The PRC concluded that, although isolated, the cooler was capable of performing its intended safety function and was operable. However, the PRC also concluded that a satisfactory 10CFR50.59 Safety Evaluation was necessary prior to isolating the room cooler. The PRC conclusions were presented to the appropriate members of the Corrective Action Review Board (CARB) and the requirement to perform a Safety Evaluation prior to this type of action was reiterated.
Corrective Actions To Be Taken To Avoid Further Noncompliance l
l Operations personnel will be informed of this occurrence. A review of the safety evaluation principles will be included. Training sessions will be conducted for PRC and CARB members to review the 10CFR50.59 requirements.
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e James G Keppler, Administrator 3
Palisades Plant-Response to IEIR 85-009 July 3, 1985-Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 15, 1985.
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David J V eWalle Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades t
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